EFTA00177622.pdf

PODHURST ORSECK TRIAL S APPELLATE LAWYERS CITY NATIONAL DANK °LOADING 25 WEST FLAGLER STREET SUITE 600 MIAMI. FLORIDA 33130-1760 1305) 356-2600 04(0? et-2W THE ENCLOSURE IS BEING SENT TO YOU WITHOUT A PERSONAL LETTER SO THAT IT MAY REACH YOU EXPEDITIOUSLY. EFTA00177622 1 EFTA00177623  U.S. Department of Justice United States Attorney Southern District ofFlorida 500 South Australian Ave., Suite 400 Palm Beach, FL 3340! December 12, 2008 VIA UNITED STATES MAIL Calle 14 N.G-25 Torre 1 Piso 10 Wall Street Institute Bogota Columbia Re: Jeffrey Epstein- Notification of Work Release Dear Ms.a: y provides you with notice By virtue of this letter, the United States Attorney's Office hereb has applied to participate in the Palm that the U.S. Attorney's Office has learned that Jeffrey Epstein program, and PBSO has granted that Beach County Sheriffs Office's ("PBSO") work release a Science Foundation at 250 South application. Mr. Epstein is reportedly working for The Florid After work each day, Mr. Epstein Australian Avenue, Suite 1404, West Palm Beach, FL 33401. e the Stockade, Mr. Epstein is returns to the Palm Beach County Stockade. While outsid Pursuant to the work release rules, electronically monitored via a GPS system and an ankle bracelet. , remain at the office throughout the work Mr. Epstein is to go directly from the Stockade to his office day, and then return directly to the Stockade. nts prior to Mr. Epstein's We regret that we were unable to inform you of these developme ation, and we only learned of his release, but our Office was never notified of Mr. Epstein's applic program. Should ou have any release more than six weeks after he began participating in the questions regarding the work r , please direct your inquiries to Captain Palm Beach Sheriff's Office, represent you with regard It is my understanding that you have not retained counsel to you inform me if you do hire an to any litigation against Mr. Epstein. It is important that attorney, or if you change your attorney so that I may communicate with you through that EFTA00177624 MISS SHASDY VELASCO NOTIFICATION OF WORK RELEASE DECEMBER 12, 2008 PAGE 2 OF 2 ence, r telephone number. As I mentioned in my earlier correspond er to represent e nd his firm were selected by an independent Special Mast which can explain. identified victims of Mr. Epstein with certain limitations, A$0in. you have no obligation to select as ygur counsel, but if you would like , to have Mr. J re resent you, you must contact him or hispartner or via e-mail at and direct! at in in your (If you contact them via e-mail please reference Mr. Epste e a claim against Mr. Epste in, Ms. e-mat .) ease note t at, even if you decide not to pursu with any counseling or other has put together a team of counselors who can assist you services that ou might need. also can continue to contact the FBI's Victim Services Coordinator, at My best wishes for a peaceful holiday season. R. Alexander Acosta United States Attorney By: Assistant .Attorney cc: EFTA00177625  Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 Case 9:08-cv-80736-KAM UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES I AND 2, Petitioners. / VE ORDER ORDER TO COMPEL PRODUCTION AND PROTECTI ore tenets motion seeking the THIS CAUSE comes before the Court on the Petitioners' d States Attorney's Office for the production of the Non-Prosecution Agreement between the Unite ("Epstein"). After consideration of the Southern District of Florida ("USAO") and Jeffrey Epstein ERED AND ADJUDGED that the Motion, the arguments of the parties, and the record, it is ORD ce the Non-Prosecution Agreement, Petitioners' Motion is GRANTED. The USAO shall produ with the following procedures: including any modifications and addenda thereto, in accordance tion Agreement, (a) The USAO shall produce a copy of the Non-Prosecu referred to as the "Agreement"), to including any modifications and addenda thereto (collectively the attorneys for Petitioners. or its terms (b) Petitioners and their attorneys shall not disclose the Agreement and an opportunity for Epstein's to any third party absent further court order, following notice to counsel to be heard. or discuss (c) Before counsel for petitioners show the Agreement to their clients to petitioners, who must review the specific terms with them, they must provide a copy of this Order of the Order. Counsel for and acknowledge their receipt of, and agreement to abide by, the terms the USAO. petitioners must promptly provide a copy of that acknowledgment to as victims of (d) If any individuals who have been identified by the USAO EFTA00177626 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attorney(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21" day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dated: k Signed by. Printed Name: 2 EFTA00177627  Entered on FLSD Docket 08/21/2008 Page 1 of 2 Case 9:08-cv-80736-KAM Document 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES 1 AND 2, Petitioners. AND PROTECTIVE ORDER ORDER TO COMPEL PRODUCTION ing the on the Petitioners' ore tenus motion seek THIS CAUSE comes before the Court ce for the ent between the United States Attorney's Offi production of the Non-Prosecution Agreem the Jeffrey Epstein ("Epstein"). After consideration of Southern District of Florida ("USAO") and GED that the the record, it is ORDERED AND ADJUD Motion, the arguments of the parties, and Agreement, USAO shall produce the Non-Prosecution Petitioners' Motion is GRANTED. The edures: eto, in accordance with the following proc including any modifications and addenda ther the Non-Prosecution Agreement, (a) The USAO shall produce a copy of reement"), to thereto (collectively referred to as the "Ag including any modifications and addenda the attorneys for Petitioners. lose the Agreement or its terms (b) Petitioners and their attorneys shall not disc Epstein's r, following notice to and an opportunity for to any third party absent further court orde counsel to be heard. eement to their clients or discuss (c) Before counsel for petitioners show the Agr t review ide a copy of this Order to petitioners, who mus the specific terms with them, they must prov nsel for nt to abide by, the terms of the Order. Cou and acknowledge their receipt of, and agreeme acknowledgment to the USAO. petitioners must promptly provide a copy of that d by the USAO as victims of (d) If any individuals who have been identifie EFTA00177628 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21° day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order DatedAACACY\ 12 ,100C1 Signed by. Printed Nam 2 EFTA00177629  PODHURST ORSECK, P.A. TRIAL & APPELLATE LAWYERS CITY NATIONAL BANK BUILDING 25 WEST YLAGLER STREET SUITE 600 MIAMI. FLORIDA 33130-17 50 13051350-1600 OJAI emi-cf - 7 dfre THE ENCLOSURE IS BEING SENT TO YOU WITHOUT A PERSONAL LETTER SO THAT IT MAY REACH YOU EXPEDITIOUSLY. EFTA00177630  Entered on FLSD Docket 08/21/2008 Page 1 of 2 Case 9:08-cv-80736-KAM Document 26 RT UNITED STATES DISTRICT COU SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES 1 AND 2, Petitioners. AND PROTECTIVE ORDER ORDER TO COMPEL PRODUCTION the on the Petitioners' ore terns motion seeking THIS CAUSE comes before the Court Office for the ent between the United States Attorney's production of the Non-Prosecution Agreem ideration of the and Jeffrey Epstein ("Epstein"). After cons Southern District of Florida ("USAO") GED that the the record, it is ORDERED AND ADJUD Motion, the arguments of the parties, and Agreement, USAO shall produce the Non-Prosecution Petitioners' Motion is GRANTED. The g procedures: thereto, in accordance with the followin including any modifications and addenda of the Non-Prosecution Agreement, (a) The USAO shall produce a copy "Agreement"), to a thereto (collectively referred to as the including any modifications and addend the attorneys for Petitioners. disclose the Agreement or its terms (b) Petitioners and their attorneys shall not 's order, followin g notice to and an opportunity for Epstein to any third party absent further court counsel to be heard. Agreement to their clients or discuss (c) Before counsel for petitioners show the must review a copy of this Order to petitioners, who the specific terms with them, they must provide nsel for nt to abide by, the terms of the Order. Cou and acknowledge their receipt of, and agreeme that acknowledgment to the USAO. petitioners must promptly provide a copy of tified by the USAO as victims of (d) If any individuals who have been iden EFTA00177631 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21" day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below I certify that I have reviewed and agree to be bound by the terms of this Order Dated: Signed by: _ Printed Name: 2 EFTA00177632 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/IOHNSON IN RE: JANE DOES 1 AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore genus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard. (c) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00177633 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attorneys) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attorneys) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 211'day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dated: 3/ Ci /6') Signed by: Printed Name: 2 EFTA00177634 Cease 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES I AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AM) PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party.absent further court order, following notice to and an opportunity for Epstein's counsel to be heariel. (c) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00177635  Entered on FLSD Docket 08/21/2008 Page 2 of 2 Case 9:08-cv-80736-KAM Document 26 ew the e individuals request the opportunity to revi Epstein and/or any attomey(s) for thos e Agreement to those individuals, so long as thos Agreement, then the USAO shall produce the party lose the Agreement or its terms to any third individuals also agree that they shall not disc d an opportunity for Epstein's counsel to be hear absent further court order, following notice to and r individuals who have been (e) Prior to producing the documents to any othe a copy and/or any attomey(s) for those individuals, identified by the USAO as victims of Epstein receipt this Ord er mus t be prov ided to said indi viduals, who must review and acknowledge their of t promptly s of this Order. Counsel for petitioners mus of, and agreement to abide by, the term the USAO. provide a copy of that acknowledgment to ida, West Palm Beach, Palm Beach County, Flor DONE and ORDERED in Chambers, in this 211 day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record and artree to be bound by the terms of this By signing below, I certify that I have reviewed Order. Dated: ) V) i9 4 Slimed by: Printed Name: 2 EFTA00177636 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRALIOHNSON IN RE: JANE DOES 1 AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard. (c) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00177637 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21" day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dated: TAO 23, 24)09 Signed by: Printed Name: 2 EFTA00177638 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES I AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard. (c) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00177639 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USA() as victims of Epstein and/or any attomey(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 2I" day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dated: O1. • 01 Signed by: Printed Nam 2 EFTA00177640 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARREJOHNSON IN RE: JANE DOES I AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore tenus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard. (c) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00177641 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attorney(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attorneys) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21U day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dated: 09 Signed by: Printed Name 2 EFTA00177642  PODHURST ORSECK, P.A. TRIAL & APPELLATE LAWYERS CITY NATIONAL BANK BUILDING 25 WEST FLAGLER STREET SUITE 000 MIAMI. FLORIDA 33I 30-1700 1305/35•-zeco THE ENCLOSURE IS BEING SENT TO YOU WITHOUT A PERSONAL LETTER SO THAT IT MAY REACH YOU EXPEDITIOUSLY. EFTA00177643 case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES I AND 2, Petitioners. ORDER TO COMPEL PRODUCTION AND PROTECTIVE ORDER THIS CAUSE comes before the Court on the Petitioners' ore genus motion seeking the production of the Non-Prosecution Agreement between the United States Attorney's Office for the Southern District of Florida ("USAO") and Jeffrey Epstein ("Epstein"). After consideration of the Motion, the arguments of the parties, and the record, it is ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED. The USAO shall produce the Non-Prosecution Agreement, including any modifications and addenda thereto, in accordance with the following procedures: (a) The USAO shall produce a copy of the Non-Prosecution Agreement, including any modifications and addenda thereto (collectively referred to as the "Agreement"), to the attorneys for Petitioners. (b) Petitioners and their attorneys shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard. (c) Before counsel for petitioners show the Agreement to their clients or discuss the specific terms with them, they must provide a copy of this Order to petitioners, who must review and acknowledge their receipt of, and agreement to abide by, the terms of the Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. (d) If any individuals who have been identified by the USAO as victims of EFTA00177644 Case 9:08-cv-80736-KAM Document 26 Entered on FLSD Docket 08/21/2008 Page 2 of 2 Epstein and/or any attomey(s) for those individuals request the opportunity to review the Agreement, then the USAO shall produce the Agreement to those individuals, so long as those individuals also agree that they shall not disclose the Agreement or its terms to any third party absent further court order, following notice to and an opportunity for Epstein's counsel to be heard (e) Prior to producing the documents to any other individuals who have been identified by the USAO as victims of Epstein and/or any attomey(s) for those individuals, a copy of this Order must be provided to said individuals, who must review and acknowledge their receipt of, and agreement to abide by, the terms of this Order. Counsel for petitioners must promptly provide a copy of that acknowledgment to the USAO. DONE and ORDERED in Chambers, in West Palm Beach, Palm Beach County, Florida, this 21" day of August, 2008. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE Copies furnished to: all counsel of record By signing below, I certify that I have reviewed and agree to be bound by the terms of this Order. Dated: 49- 24/08 Signed by: Printed Name: 2 EFTA00177645  Entered on FLSD Docket 08/21/2008 Page 1 of 2 Case 9:08-cv-80736-KAM Document 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOES I AND 2, Petitioners. VE ORDER ORDER TO COMPEL PRODUCTION AND PROTECTI ore tenus motion seeking the THIS CAUSE comes before the Court on the Petitioners' United States Attorney's Office for the production of the Non-Prosecution Agreement between the n ("Epstein"). After consideration of the Southern District of Florida ("USAO") and Jeffrey Epstei RED AND ADJUDGED that the Motion, the arguments of the parties, and the record, it is ORDE ce the Non-Prosecution Agreement, Petitioners' Motion is GRANTED. The USAO shall produ ance with the following procedures: including any modifications and addenda thereto, in accord tion Agreement, (a) The USAO shall produce a copy of the Non-Prosecu ctively referred to as the "Agreement"), to including any modifications and addenda thereto (colle the attorneys for Petitioners. or its terms (b)